This arises out of
a
relationship between
a woman and a man. The woman, the defendant here, wanted a
"serious"
relationship and the man, the plaintiff here, wanted a friendship. The
plaintiff was in the middle of a divorce and a serious relationship was
premature. Feeling scorned and rejected and wanting more
attention,
the woman began threatening the man and writing defamatory things about
him to diverse people, including friends of his. Ultimately, the woman
began talking defamatorily to the attorney for the man's wife and then with
the guardian ad litem.

By her actions,
defendant intentionally
inflicted emotional distress on the plaintiff, John Smith.

PARTIES

1. Plaintiff John
Smith
["Smith"] is
a natural person residing at 00 XXXXX Road, TOWN, County, Massachusetts
00000-0000; was a resident of TOWN, Massachusetts. during all relevant
times of this action; is married to Pocahontas Doe Smith; and is the
biological
father of Zach Doe Smith and John Doe Smith.

2. Defendant MEDUSA
['MEDUSA"] is a
natural person residing at 00 YYYYYY Street, CITY, County,
Massachusetts,
00000; was a resident of CITY, Massachusetts,
during all relevant
times of this action; and is unmarried.

COUNT
1: DEFAMATION

3. Smith repeats
and
realleges and
incorporates by reference the allegations in paragraphs
1 and 2
above with the same force and effect as if herein set forth.

4. Defendant MEDUSA
published one or
more oral and written false statements which were intended to impeach
Plaintiff
Smith's honesty, integrity, virtue, or reputation.

5. The defamatory
statements were,
including, but not limited to, the following:

a.
"MEDUSA stated to ASPY GAL that Smith, `will do what it takes to get
custody,
that his judgment is blurred, that he has crossed a line...'" Thursday,
15 March 2001; b.
"Johnny is mean, he doesn't have the heart of gold that everyone thinks
he does," Thursday, 15 March 2001 at 07:57:46;

c.
"I'm concerned about him parenting the boys," Thursday, 15 March 2001
at
07:57:46;

d.
"I don't think Johnny is telling either of you the truth," Monday, 12
March
2001 at 03:36 PM and republished Thursday, 15 March 2001 at 07:57:55;

e.
"Johnny did something TODAY that is going to hurt his kids GREATLY. If
you knew about it ahead of time, you should have stopped him. If you don't
know, you
should ask him what he's up to before telling ME where to go...He's
dangerous
at this point. He's done a really good job
of
giving the
`poor me' act to us all, but he's a wolf in sheep's
clothing." Republished
on Thursday, 15 Mar 2001 07:58:02;

f.
"Johnny DID do something yesterday that was really bad for his kids, it has nothing to do
with me
and him. If you want to be a friend to HIM, you should ask him about it
and suggest that he retract his actions, immediately,
somehow. He's
already made it so he's lost visitation effective immediately. And I
think
he's ALREADY dug his own
grave on the whole
case. And,
I know all this for a FACT, it's not my opinion.

"Why aren't I
telling
Johnny all this?
Because somehow he's gone off the deep end and won't listen to reason
anymore."
Published on Tuesday, Mar 13, 2001, 1:34 AM and republished on
Thursday,
15 Mar 2001 07:58:06;

g.
"Johnny has shown me directly that he can lie while looking me straight
in the face, be controlling, vengeful, neglectful, manipulative,
emotionally
unstable, have a horrible temper, and most of all be very
self-centered.
. . .

"He has asked me to
write lies when
writing documents, and to write things that never happened, while
angrily
telling me that I just don't remember it correctly. I've had to show
him
documentation to the contrary, at which point he has told me to destroy
it. I am not an attorney, and do not know what position this puts me in
now. I hope that I will not need my
own attorney,
I cannot afford one. BUT, I refuse to lie for him anymore."
Published
Monday, 19 February 2001 at 14:54:00;

h.
"Briefly, Johnny has just yesterday brought certain allegations to the court's attention that
are going
to be very traumatic to his boys, and it's going to deny him
visitation
altogether, and maybe any chance at custody. I've already made a few
phone
calls, and because I have shared my knowledge of Johnny's actions, I'm
told I will probably be subpoenaed.

"Johnny has pushed
me
away and will
not listen to why his actions were wrong. I think he's
become desperate,
and I am wondering if someone from the Fathers' Group can try to call
him.
I am afraid that he
has resorted to other
than honest
or ethical tactics in a desperate effort to grab his twins away from
his
wife. I think it's as a result of feeling that the system, especially
the
GAL and XXX (child protective services), is against him. He said to me
`You people haven't gotten anywhere, so I have had to take care of it
myself.'
He's lumping me in with `you people', and as you know, I'm not one of
`them'.

"It's taken me a
few
days to think
clearly about contacting you, but I think Johnny is in trouble
and needs
help. Over the past month or so, I've suggested he see a councilor, and
he has refused...." Published Tuesday, 13 Mar 2001 at 21:41:50 and
republished
Saturday, 17 March 2001 at 14:12:49;

i.
"I have a lot more insight about Johnny through talking to the GAL, and
it seems clear that from the beginning of the case, Johnny has been
encouraged
to go to therapy. Johnny never said anything about this to me, nor has
he considered going to therapy. And when I've mentioned it on my own,
he
told me to never suggest it again. His refusal to go is one of the
biggest
reasons why he won't get the kids. This is what I've heard.

"Also, ASPY GAL is
absolutely NOT AT
ALL the horrible person Johnny has made her out to
be. She's
very impartial and compassionate, and has given Johnny a lot of
consideration.
I have the clear
impression that
Johnny's
perspective on everything is VERY far off-base, and that he has
`invented'
alot of what he has told us (you guys and me) about this case."
Published
__ March 2001 and republished Saturday, 17 Mar 2001 at 21:47:47.

6. Smith is not a
public
figure.

7. The statements
imputed by MEDUSA
to Smith, the slurs on Smith's character by MEDUSA, including his
honesty,
integrity, virtue, or reputation, the oral and written statements by
MEDUSA
that he was unstable or had poor judgment or was inflicted with a
mental
illness needing treatment defamed Smith.

8. The defamatory
statements resulted
in liability to Smith.

WHEREFORE,
Plaintiff
John Smith demands
judgment against Defendant MEDUSA for injunctive relief and actual,
special,
and compensatory damages in an amount deemed at time of trial to be
just,
fair, and appropriate.

COUNT
2: INTENTIONAL
INFLICTION OF EMOTIONAL DISTRESS

9. Smith repeats
and
realleges and
incorporates by reference the allegations in paragraphs
1 through
8 above with the same force and effect as if herein set forth.

10. Defendant
MEDUSA
intentionally
and deliberately inflicted emotional distress on Smith by defaming him
to many people, including but not limited to the following: several of
Smith's friends, his counsel, counsel of Smith's wife's, the guardian ad
litem of Smith's children.

11. As a result of
MEDUSA's extreme
and outrageous conduct, Smith was, is, and, with a high degree of
likelihood,
will continue to be emotionally distressed due to her defamation of him.

12. As a result of
MEDUSA's extreme
and outrageous conduct, Smith has suffered and will continue to suffer
mental pain and anguish, severe emotional trauma, embarrassment, and
humiliation.

WHEREFORE, Plaintiff
Smith demands
judgment, including interest, against the Defendant MEDUSA in an amount
deemed by this Court to be just and fair and in any other way in which
the Court deems appropriate.